Effective September 5, 2023
Welcome to Deem—One number. Endless possibilities.
Note that we will not send you marketing materials unless you separately opt-in to receive those marketing communications, and you may opt-out of those marketing communications at any time.
1.0 SCOPE AND EFFECTIVE DATE
Note that use of the Deem Services includes your optional use of third-party services such as the services of our company subscribers. You should carefully review the privacy policies of those third-parties to understand their use of your personal information when you sign up for their offerings and services through the Deem Services.
2.0 CHILDREN UNDER THE AGE OF 18
The Services are not intended for anyone under the age of eighteen (18) years old. We do not knowingly collect personal information from anyone under eighteen (18) years old. If you are under the age of eighteen (18) years old, do not use the Services, provide any information, use any of the interactive features of our Services, or provide any information about yourself to us.
3.0 TYPES OF INFORMATION COLLECTED
The information Deem collects from you differs based on type of account you set up with us and the Services you use. We may collect the following categories of information:
- Consumer Account Information. When you create a Consumer Account (as defined in the Consumer Agreement), we may collect certain personal information that can be used to identify you, such as your full name, email address, password, phone number, and any additional option information you choose to provide us. We may also collect additional information such as communication preferences, and other information to allow us to provide more personalized Services.
- Financial Information. In connection with a financial transaction executed via the Services, we or our third-party payment service providers may collect your credit or debit card information, digital wallet address, or other financial payment information. We may directly collect or store payment card or financial information entered through our Services including the last four digits of your payment card or financial information and may receive other information associated with your payment card information (e.g., your billing details). We (or our third-party service providers) may collect your transaction, digital wallet addresses, and purchase history details.
- Your Communications with Us. We may collect personal information from you such as your full name, email address, phone number, social media identifier, or mailing address when you request information about our Services, request customer or technical support, including messages you submit through support conversations, apply for a job, or otherwise communicate with us. We may also contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information, which may include personal information. For any technical or customer support that requires the use of session replay or other screen sharing technologies that collect your personal information, we will ask for your consent at the point of collection.
In addition to the information we may request that you provide us, we may also automatically collect personal information when you use our services such as:
- Automatic Online Data Collection. We, as well as third parties that participate on the platform, or other functionality on the Services, may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, media access control address (MAC address), cookie identifiers, mobile carrier, and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during, and after using the Services, information about the links you click, digital wallet providers, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
While the Deem Services allow authorized third parties to authenticate individuals through their biometric phone logins, Deem does not actually collect or store any biometric information itself. Please refer to your applicable third-party service provider’s policies over the use and storage of your biometric information.
4.0 USE OF INFORMATION
We do not sell your personal information. However, we may use your information in connection with our Services and Site for a variety of business and administrative purposes, including to provide our Services, and for administrative purposes as described below:
- Site Functionality. We may use the above information to manage your Consumer Account, provide access to certain Site and Services functionalities, answer questions and assist with technical support issues, communicate with you regarding our Site or Services, provide analytics services, assist with automated transactions (such as reminding you about the availability of digital tokens or NFTs or other digital tokens provide you the means to perform activities or transact with third party goods or services providers), and other administrative purposes.
- Security. We may also use the information to better protect the Services, the Site, and users’ experience on the Site. This includes information used to: (1) screen against potential risks, fraud, and to generally improve and optimize the Site; (2) comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights; (3) identify and repair errors with our Services and Site and for improving, upgrading, or enhancing the Services and Site; (4) investigate and ensure compliance with our Consumer Agreement and other policies; and (5) ensuring internal quality control and safety.
- Marketing. We will never send you marketing or promotional materials unless you separately opt-in to receive those communications, and you may opt-out of those communications at any time. Please carefully review any such separate opt-in agreement to understand the marketing communications you are consenting to receive. You can always remove consent to receive marketing communications by contacting us as firstname.lastname@example.org.
5.0 WHO MAY ACCESS INFORMATION
In addition to our internal use of information as described above, we may disclose your information to third parties for a variety of business purposes such as:
- Contractors. We may disclose information to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
- Business Partners. We may share your personal information to business partners with whom we jointly offer products or services.
- Law Enforcement/Governmental Agencies. We may share your personal information if required or appropriate to comply with law enforcement, national security requests, or legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
- Acquiring Parties. If we sell all or substantially all of our assets, or are otherwise acquired, your personal information may be transferred to a third party. We may also transfer or assign personal information to a third party in the event of some other change of control (such as the result of a bankruptcy proceeding).
6.0 YOUR RIGHTS TO INFORMATION.
To the extent required by applicable law, you may have the right to:
- Access your Information. You may have the right to request access to your information including obtaining access to, or a copy of, your personal information in a structured, commonly used, and machine readable format.
- Request Information Deletion/Correction. You may request to correct your personal information where it is inaccurate or incomplete. You may also request that some or all of your personal information be deleted, subject to certain exceptions prescribed by law.
7.0 INFORMATION RETENTION
We may retain any personal information that you have provided to us unless and until you ask us to delete this information or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. You may send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us. The deletion of user information may result in loss of Site functionality for that user. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you are a European resident, please note that your information will be transferred outside of Europe, including to Canada and the United States. If we transfer personal information to countries outside the European Economic Area, we will put in place appropriate safeguards as required by applicable law to ensure that this transfer complies with the applicable laws and regulations and require our third-party service providers and partners to have appropriate safeguards as well.
8.0 CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), applies solely to individuals, who are residents of the State of California. The CCPA provides consumers (California residents) with specific rights regarding their personal information. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
To make a request related to your personal information rights under the CCPA, please contact us at firstname.lastname@example.org.